Torres. RobertoJ

From: Sent: To: Torres, RobertoJ Subject:

Attachments: NRC Mount Sopris.pdf

Lindigrin, John A ERDC-SO-MS [John.A.Lindigrin@usace.army.mil] Tuesday, October 11, 201 1 4:20 PM

Amendment To NRC License No. 23-01544-09, Mail Control Number 575611 ( U N C LASS I F I ED)

Classification: UNCLASSIFIED Caveats: NONE

Mr. Torres,

Please see attached file which should answer your questions. Please let me know if you need more information.

Thanks John Lindigrin

Classification: UNCLASSIFIED Caveats: NONE

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DEPARTMENT OF THE ARMY ENGINEER RESEARCH AND DEVELOPMENT CENTER, CORPS OF ENGINEERS

WATERWAYS EXPERIMENT STATION, 3909 HALLS FERRY ROAD VICKSBURG, MISSISSIPPI 39180-6199

October 11,2011

Safety and Environmental Management Office

U.S. Nuclear Regulatory Commission Region IV ATTN: Roberto J. Torres, Senior Health Physicist 612 East Lamar Blvd., Suite 400 Arlington, Texas 76011-4125

SUBJECT: REQUEST FOR ADDITIONAL INFORMATION (MAIL CONTROL NUMBER 575611)

Reference is made to your letter dated August 31,2011 requesting additional information regarding ERDC's request for amendment to NRC License Number 23-01544-09 to add a Mount Sopris Instrument Company, Model 2GDA-1000 DX Series, well logging density probe. Answers to your questions are as follows:

1. There is no SSDR certificate for the Mount Sopris Instrument Company, Model 2GDA-1000 DX Series device.

2. The U.S. Army Aviation Missile Command, AMSAM-TMD-SD (Dosimetry Center), Building 5417, Redstone Arsenal, Alabama 35898-5000, is currently accredited as a dosimetry processor by NVLAP. See attached accreditation.

3. The ERDC, Waterways Experiment Station, has the following Radiation detection instruments:

a. Two Eberline Model E-120 Meters equipped with Eberline HP-270 probes.

b. One Ludlum Measurements, Inc. Model 2224 equipped with a Ludlum Model 43-93 probe

All instruments are calibrated by Ludlum Measurements, Inc. ,501 Oak Street, Sweetwater, Texas 79556 on six month intervals.

4. See paragraph 16 of the attached Standard Operating and Emergency Procedures for instructions for handling licensed material in wells without surface casing for protecting fresh water aquifers.

5. See attached Instructions For Receiving and Opening Packages Containing Radioactive Material.

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6. See paragraph 14 of the attached Standard Operating and Emergency Procedures for procedures describing semiannual maintenance of well logging density probe.

7. The statement “ERDC employees would not remove the encapsulated source from the source holder.” has been deleted from the Standard Operating and Emergency Procedures. Paragraph 17 has been added to cover leak testing procedures.

8. Analysis of ERDC leak test samples will be done by the U. S. Army Public Health Command, 5158 Blackhawk Road, Aberdeen proving Ground, Maryland 21010-5403. Their NRC license Number is 19-09880-01 and expires April 30,2016.

Thank you for your assistance in this matter.

Sincerely, i

G R D C R a d i w y Officer

Enclosures

r4 nij I /i d iJ National Voluntary

- .-- Laboratory Accreditation Progra

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STANDARD OPERATING AND EMERGENCY PROCEDURES: Dual Density/Guard/Caliper Probe

(Manufacturer's User Manual attached as part of this SOP, attachment 1)

A. Standard Operations

1.Tool: Dual Density/Guard/Caliper Probe Model 2 GDA - 1000 DX manufactured by Mount Sopris Instrument Co., Inc, Golden, CO. When in use, the tool contains a triple encapsulated, 100 millicurie Cesium 137 source, model No. HEG 137 manufactured by Eckert & Ziegler - Isotope Product Laboratories. The NRC Registry No. is CA0406S122S. The encapsulated source meets ANSI N542-1977. The registration is for a maximum of 600 millicuries.

2. Use: The tool is lowered on a data transmission and support cable into a borehole to collect geophysical data from the surrounding earth materials. The tool collects soil density data for research on modeling of effects of geologic properties on various sensors. The tool will be used in cased and uncased holes with appropriate precautions as stated in this Standard Operating Procedure (SOP). The tool may also be used below the water table of fresh water aquifers.

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3. Training for Logging Supervisors and Logging Assistants: Logging Supervisors and Logging Assistants will receive training as specified in 10 CFR 39.61. Initial training will be conducted by a qualified instructor to include radiation safety, radiation detection instruments, installation of the sealed source into the source holder, installation of the source holder containing the source into the tool, and use of the tool with source installed. Initial training will also include requirements of pertinent Federal regulations, a review of the NRC license, review of operating and emergency procedures, and case histories of accidents in well logging. A written test will be administered and a passing grade of 80% will be required to certify training complete. Records of initial training will be maintained as long as a particular employee is qualified to operate the tool.

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4. Safety reviews and annual refresher training will include review of selected initial training topics and will emphasize recent operational issues involving use of the tool. Records of annual refresher training and safety reviews will be retained until 3 years after termination of employment or 3 years after training and review whichever is longer.

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5. Annual Internal Job Performance Inspections: Each logging supervisor and logging assistant will receive an inspection annually or, if they have not used the tool for over 12 months, a t the first subsequent use of the tool. The inspection will determine if the regulations, license requirements, and operating and emergency procedures are being followed. Records of the inspections will be maintained for 3 years after each inspection.

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6. Transportation: The tool will be transported in accordance with Department of Transportation 49 CFR for transportation on public roads and highways.

7. Notification for military installations: When the tool and source are transported to a military installation, the installation's RSO (Radiation Safety Officer)/safety office will be notified before bringing the source onto the installation. z 7 d

8. Storage and Security: A t all times when not in use, the source will be double secured. Double secure storage of the source at the Engineer Research and Development Center (ERDC) will be provided by the ERDC RSO. While the source is away from ERDC, the source, when not in use, will be doubled secured by placing the source holder with source in the locked source shield or pig assembly supplied by the manufacturer and the pig assembly containing the source holder and source will be physically secured to the inside of a locked vehicle. The ERDC RSO will be responsible for ensuring day to day oversight of the radiation safety when the source is in storage a t ERDC. The logging supervisor will be responsible for day to day oversight of the radiation safety when the source is a t or enroute to or from the field site.

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9. Survey Instruments: Sufficient calibrated and operable radiation survey instruments will accompany logging sources to the field to make physical radiation surveys as required by section 20.1501 of 10 CFR 20, and for making site surveys when required. Ensure the survey instruments have been calibrated within the last six months. A response check shall be performed on the survey instrument prior to use.

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10. Documents to Accompany Source to Field Sites: jp$t a. NRC License.

b. Source usage form (attachment 2).

c. Vehicle survey form (attachment 3).

d. Well owner agreement form, if needed (survey site not on military installation).

e. Shipping papers (to be in cab of vehicle, within arm's reach of driver).

f. Standard Operating and Emergency Procedures.

g. NUREG 1556 Vol. 14.

h. 10 CFR 20.

i. 10 CFR 39.

j. Radiation survey instrument's current semi-annual calibration record.

k. Mount Sopris user's manual for the 2GDA-1000 DX Series Density Probe (attachment 1).

11. Source usage form (attachment 2). A record of each time the source is used or put into or removed from the shield shall be maintained. This record shall have the following minimum information:

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a. Date

b. Source identification

c. Time out (removed from shield).

d. Time in (reinstalled into shield).

e. Any remarks concerning use of the source.

f. Identification of individual responsible.

12. Vehicle survey form (attachment 3). A radiation survey shall be made before commencing a trip, upon completion of the logging, and upon return from a trip. This shall be recorded on the vehicle survey form and will contain the following information:

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a. Date

b. Survey instrument used and its last calibration date.

c. Maximum radiation reading on each of the vehicle's four sides.

d. Readings in operator's compartment.

e. Readings on contact of each source shield.

f. Identification of individual making survey.

13. Inspections of Tool Prior to Use: The tool and support equipment will be inspected prior to use to detect any defects, damage, or other conditions that would prevent safe and proper operation of the tool.

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14. Semiannual Visual Inspection and Maintenance: A semiannual visual inspection and routine maintenance will be conducted on the source holder, tool, source handling tools and storage and transport containers. Insure that required labeling is in place and legible and no physical damage is

evident. Maintain inspection, maintenance, and repair records for 3 years after any defect is found.

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15. Use of Source: Step by step procedures to remove the source holder with source from the shield and install it on the tool are provided on pages 13-15 of the Mount Sopris user manual (attachment 1). Whenever logging with a radioactive source, the tool with the radioactive source is to be the last tool in

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the well. All users of the tool will be trained on the use of the tool and on radiation safety and be issued a dosimeter by the ERDC RSO for wearing when near the source. Use of the tool, including loading of the source holder with source onto the tool will follow the manufacturer's guidance manual attached as part of this standard operating procedure (SOP). At a minimum, a caliper log will be used in the well before a tool with a source to determine well conditions. Two caliper logs may be required in open holes (uncased) during logging operations to check wellbore deterioration with time. If conditions are found that could cause loss of the tool, DO NOT RUN A RADIOACTIVE TOOL IN THE HOLE. This will minimize the risk of losing a radioactive source down a well and help protect fresh water aquifers. Keep bystanders (not authorized to receive radiation exposure) at least 25 ft. from the logging tools with radioactive sources.

16. Use of Source in Fresh Water Aquifers: If the tool is used in fresh water aquifers, the logging

available sources. A caliper log will be run to determine if the hole is sufficiently clear and intact or if there are problem areas. A tool with a radioactive source will be run in the hole to demonstrate that the tool will move freely and is easily retrieved from the hole. If there are problems with the hole, temporary casing may be placed to insure free movement of the tool in the hole. If any conditions are found that could cause loss of the tool, DO NOT RUN A RADIOACTIVE TOOL IN THE HOLE.

& supervisor will obtain specific knowledge of the borehole from the owner, drilling team or any other $7

iS 17. Leak Testing: Leak testing will follow the procedures in the manufacturer's manual (atch l), page* The 24 hour Radiological Safety Training course given for logging supervisors conducted in August 2011 included radiation safety aspects of handling an unshielded source (documented in training manual for course). Certificates are on file a t the ERDC safety office for the individuals who took the course. Leak tests are performed every 6 months and records are kept for 3 years.

18. Well Ownerloperator Agreements: The tool will primarily be used on Federal property. If the tool is employed on other than Federal property a written agreement will be obtained prior to well logging with the radioactive source. The agreement will meet the requirements specified in 10 CFR 39.15 (see NUREG - 1556, Vol. 14 Appendix U for sample format).

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B. Emergency Procedures

1. For all emergences all necessary precautions will be taken to prevent exposure of anyone to the source or source material. In case of vehicle accident, fire, explosion, theft, ruptured source, or any other emergency, first contact local authorities such as, post security, post RSO/safety office, police, sheriff, or state police as appropriate to location. Immediately notify the ERDC RSO.

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2. In the event of an accident: sr" a. Remove injured, if necessary.

b. Keep bystanders at least 25 ft. from logging tools with radioactive sources.

c. Call or send for help.

d. Perform radiation survey if instruments are accessible.

e. Evacuate the area if necessary.

f. If there is a fire, explosion, or ruptured source:

1. it may be possible to breath in radioactive particulates. Keep everyone upwind.

2. Notify al l personnel in the area immediately.

3. Notify the fire department.

4. Attempt to put out the fire if radiation hazard or explosion hazard is not present.

5. If source is ruptured await arrival of emergency response.

g. Following the emergency, ensure all personnel involved in combating the emergency are monitored.

h. In coordination with the ERDC RSO and any local safety office /RSO monitor the area and determine if any decontamination is necessary. Decontamination will be as directed or arranged by the ERDC RSO.

i. Prepare a complete history of events and forward to the ERDC RSO.

3. Retrieval of a Source Stuck in a Borehole: If the tool with the source becomes stuck in the borehole, all nondestructive measures will be taken to recover the source. These measures may include but not be I i mi ted to:

-Digging down to the depth at which the source is stuck.

-Pulling the casing in which the source is stuck.

-Over drilling the hole to the depth a t which the source is stuck.

-Using an appropriate lubricating liquid.

The ERDC RSO will be notified and efforts to retrieve the source will be coordinated with the ERDC RSO. If there are circulating fluids from the well 10 CFR 39.69 (c) will be followed.

4. Irretrievable source: If the source cannot be retrieved the requirements of 10 CFR 39.15(a)(5) will be met.

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ia@idr" 5. Ruptured Sealed source: If the licensee detects evidence that a sealed source has ruptured or licensed materials have caused contamination, the licensee shall initiate the emergency procedures required by 10 CFR 39.63. Actions specified in NUREG 1556, Vol. 14, Appendix V will be taken.

INSTUCTIONS FOR RECEIVING AND OPE"C3 PACKAGES CONTAINT?S G RADIOACTIVE MA m w

1. When a package containing radioactive material is received it will be inspected as follows:

a. Upon receipt of a package, the users shall notify the RPO immediately or not less than 3 hours from the beginning of the next working day if it is received after normal working hours.

b, When a radioactive material package is received, there is a chance the radiactive material has leaked out of the h e r container. Always assume a radioactive material package is contaminated until proven otherwise.

c. A visual check is m@@@ see ifthe package is damaged (wet or crushed). Ifthere is evidence of degradation ?$the package integrity, the package will be wipe tested for radioactive contamination and radiafion levels.

d. Wipe test the external surface of a labeled package (a package labeled with a Radioactive White I, Yellow IT, or Yellow III ) for contamination unless the package contains only radioactive material in the form of gas or in special fofm as dt?fine!d in 10 CFR 20 or any paokage that appears damaged or if the wipe test results from the shipper are not documented.

e. Survey the external fllrfaces of a labeled package for radiation levels.

2. When opening a package containing radioactive material the following procedures will be followed:

a. Weargloves.

b. Check to make sure the contents match the packing slip.

c. Remove and wipe test the h e r container if contamination is suspected.

d. If contamination is not found, put the radioactive material in an approved storage area.

e. If contamination is found, dispose of all contaminated shipping material as radioactive waste.

f. Deface or remove all labels on uncontaminated shipping box and dispose of a~ normal trash.